On 11 March 2025, the Swiss Financial Market Supervisory Authority (FINMA) published a Press Release on the status of licences issued to portfolio managers and trustees, following the implementation of the Swiss Financial Institutions Act (FinIA). The release details the progress of applications submitted under the new licensing requirements introduced in January 2020.
Since the entry into force of Swiss FinIA on 1 January 2020, portfolio managers and trustees operating commercially in Switzerland have been required to obtain a FINMA licence. A three-year transitional period was granted for existing institutions, concluding at the end of 2022. FINMA received 1,699 applications before this deadline and has since processed 94% of these applications by the end of February 2025. In total, 1,532 out of 1,864 applications submitted since the introduction of the requirement have been approved. 131 applications were withdrawn, while 94 remain under review, with half of these cases involving investigations related to criminal proceedings or compliance issues.
Despite early guidance from FINMA, the majority of applications were submitted in the final four months of the transitional period, leading to delays. More than 40% of applications required at least five rounds of amendments before approval.
As at 28 February 2025, FINMA had approved 1,428 out of 1,699 applications submitted before 2023, and 104 out of 165 applications submitted after 1 January 2023. According to Ongoing Supervision and Regulatory Oversight
Licensed institutions are required to obtain FINMA approval for regulatory changes, and 3,221 change requests have already been processed. Going forward, FINMA expects to receive around 1,700 change requests per year. The two-tier supervisory model remains in place, with supervisory organisations (SOs) overseeing portfolio managers and trustees, while FINMA intervenes where compliance violations arise. The number of escalations to FINMA and institutions under intensive supervision increased in the second half of 2024, reflecting heightened regulatory scrutiny.
FINMA CEO Stefan Walter stated: “Thanks to the new licensing requirements, FINMA has established a high quality standard across the board. Anyone who entrusts their money to a portfolio manager or trustee should be able to assume that adequate minimum standards are in place and that these are monitored,”
Marianne Bourgoz Gorgé, Head of the Asset Management Division, stated: “A good two years after the end of the transitional period, of all the applications we received by the end of 2022, only those with either increased complexity or those that could not yet be approved due to slow feedback from applicants or lack of compliance with legal requirements are still pending. Those institutes may continue their activities until FINMA makes its final decision. FINMA will continue to work actively to ensure that progress is made in these cases. However, the majority of the licensing dossiers, over 94%, have now been concluded.”
(Source: https://www.finma.ch/en/news/2025/03/20250311-mm-abschluss-uvv/, https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/8news/medienmitteilungen/2025/03/20250311-mm-abschluss-uvv.pdf?sc_lang=en&hash=D7124330E65F4DB51C64581F46A08D97)
